Challenges in Environmental Impact Assessments for Wind Energy Projects in South Africa
occasionally leads to the abandonment of the project. Environmental investigations prior to the EIA process can avoid costly and time-consuming issues arising during the EIA process. For example, a pre-EIA screening study can identify issues such as critical biodiversity areas, priority freshwater ecosystems and important bird areas. Existing spatial data on ecological and social properties are available at national and regional levels and can be used for high-level screening and comparison of proposed sites. These data sources are readily available on the Internet and are continuously being improved and updated. However, they do remain incomplete for many remote areas of the country where renewable energy developments are being proposed.
Emerging and Evolving Guidelines
In South Africa, the EIA process that applies to renewable energy projects is promulgated under the NEMA. The processes for basic assessment and scoping and impact assessment are clearly defined in the EIA Regulations, published in Government Notice (GN) R 543 in the Government Gazette of 18 June 2010. These regulations are promulgated in terms of NEMA and as corrected by Correction Notice 1 (GN R 660 of 30 July 2010) and Correction Notice 2 (GN R 1159 of 10 December 2010).
The renewable energy industry is still in an early developmental phase in South Africa and is evolving rapidly. Consequently, new guidelines and requirements for the EIA process are released frequently in order to better inform the assessment of renewable energy projects. For example, the Guidelines for Avian Monitoring at Wind Energy Developments1 the Guidelines for Surveying Bats in Wind Farm Developments2 released in early 2011. It was then announced by the Endangered
and were
Wildlife Trust and BirdLife South Africa in March 2011 that, in their opinion, pre-construction monitoring of birds and bats should be mandatory for a minimum period of 12 months for all proposed wind energy facilities. Also during 2011, the National Department of Water
Intense legal scrutiny led to a ‘tick the box’ review approach focusing on legal compliance rather than the philosophy of integrated environmental management promoted by the Department of
Environmental Affairs.
Affairs indicated that any development within 500 m of the boundary of any wetland requires a water use license. The National Department of Agriculture during this time also indicated that it has drafted guidelines stating it will not support any renewable energy projects on cultivated land. These guidelines are not publicly available.
New and updated guidelines bring about the late involvement of some government departments in on-going EIA processes and impose additional requirements at the final stages of some EIAs, or even post-environmental authorisation. Although the release
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